| 200319011(PDF, 742K) |
2/14/2003 |
| Requested ruling concerning Plan X under § 403(b)(7) of the Internal Revenue Code. |
| 200319010(PDF, 186K) |
2/14/2003 |
| Requested ruling that the proposed amendment to the Pension Plan described in Exhibit B of that Request is reasonable and provides only for de minimis increases in Pension Plan liabilities within the meaning of § 401(a)(33) of the Internal Revenue Code and 204(i) of the Employment Retirement Income Security Act of 1974 (ERISA), has been denied. |
| 200319009(PDF, 720K) |
2/12/2003 |
| Requested ruling concerning the treatment of a proposed grant by the Foundation to a public charity involving § 4941, 4942 and 4945 of the Internal Revenue Code. |
| 200319008(PDF, 511K) |
2/12/2003 |
| Requesting relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200319007(PDF, 16K) |
5/9/2003 |
| *PULLED* |
| 200319006(PDF, 43K) |
5/9/2003 |
| Issues: Whether the Internal Revenue Service must obtain judicial approval, pursuant to Internal Revenue Code § 6334(e)(1), prior to seizure of residential property titled in the name of a trust created pursuant to an abusive trust scheme, where the Service has made assessments against both the trust and the individual using the property as a principal residence. |
| 200319005(PDF, 56K) |
5/9/2003 |
| Requested rulings regarding the income, gift, and generation-skipping transfer tax consequences of the proposed consolidation of certain trusts. |
| 200319004(PDF, 56K) |
5/9/2003 |
| Requested rulings regarding the income, gift, and generation-skipping transfer tax consequences of the proposed consolidation of certain trusts. |
| 200319003(PDF, 28K) |
5/9/2003 |
| Requested extension of time to make an election under § 42(g)(1) of the Internal Revenue Code pursuant to § 301.9100-1 of the Procedure and Administration Regulations. |
| 200319002(PDF, 76K) |
5/9/2003 |
| Requested ruling concerning the Federal gift tax treatment of the proposed transfer of your interest in a trust. |
| 200319001(PDF, 127K) |
5/9/2003 |
| Issues: (1) Whether the retroactive reformation of GRATs 1-4 to provide for a retained annuity payable for a specified term of years that was upheld in Walton v. Commissioner, 115 T.C. 589 (2000), as a qualified annuity interest under § 2702 of the Internal Revenue Code, is effective for gift tax purposes. (2) Whether or not the amendments to GRATs 1-4 are effective, should the value of the Grantor’s retained interest be determined based on the value of an annuity payable for a specified term to either the Grantor or the Grantor’s estate, because of Grantor’s testamentary general power of appointment that would be effective if the Grantor died prior to the expiration of the annuity term of the GRATs. (3) If the reformation is not effective, whether the IRS position, that the revocable spousal interests provided in GRATs 1-4 prior to reformation are not qualified interests, should be applied without retroactive effect under § 7805(b). |
| 200318076(PDF, 926K) |
2/7/2003 |
| Requested ruling concerning whether Entity B, satisfies the requirements of § 514(c)(9) to exempt income received by Trust M in connection with Lots 1 through 4 from the unrelated business income tax under § 512 of the Code. |
| 200318075(PDF, 292K) |
2/10/2003 |
| Requested advance approval of the grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200318074(PDF, 519K) |
2/6/2003 |
| Requested ruling concerning the federal income tax treatment of certain contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200318073(PDF, 311K) |
2/4/2003 |
| Requesting advance approval of grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200318072(PDF, 563K) |
2/4/2003 |
| Requesting approval of set-aside under § 4942(g)(2) of the Internal Revenue Code and § 53.4942(a)-3(b) of the Foundation and Similar Excise Tax Regulations, and a determination that the amount set aside may be treated as a qualifying distribution |
| 200318071(PDF, 574K) |
2/4/2003 |
| Requesting approval of set-aside under § 4942(g)(2) of the Internal Revenue Code and § 53.4942(a)-3(b) of the Foundation and Similar Excise Tax Regulations, and a determination that the amount set aside may be treated as a qualifying distribution |
| 200318070(PDF, 555K) |
2/4/2003 |
| Requesting approval of set-aside under § 4942(g)(2) of the Internal Revenue Code and § 53.4942(a)-3(b) of the Foundation and Similar Excise Tax Regulations, and a determination that the amount set aside may be treated as a qualifying distribution in the year in which it is set aside (but not in the year in which actually paid). |
| 200318069(PDF, 887K) |
2/3/2003 |
| Requested ruling on whether the excise tax provision of Chapter 42 of the Internal Revenue Code are violated by a proposed investment as more fully set forth below. |
| 200318068(PDF, 25K) |
5/2/2003 |
| Requesting that Taxpayer be granted an extension of time under Treasury Regulation§ 301.9100-3 to file the agreement provided under Treas. Reg. § 1.1503-2(g)(2)(i) to use the dual consolidated losses incurred by Company for the tax year ended on Date A. |
| 200318067(PDF, 77K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200318066(PDF, 74K) |
5/2/2003 |
| Requested rulings on behalf of Project Partnership, regarding Project Partnership’s qualification for tax credits under § 45 of the Internal Revenue Code from an aa megawatt wind-based generation project consisting of bb separate cc MW wind turbine generators located in County (Project). |
| 200318065(PDF, 23K) |
5/2/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200318064(PDF, 46K) |
5/2/2003 |
| Requested rulings regarding the federal income and gift tax consequences of proposed amendments to a trust. Specifically, you have requested rulings that the amendments to the terms of the trust do not give rise to gain or loss under § 1001 of the Internal Revenue Code or to gift tax consequences under § 2501. |
| 200318063(PDF, 44K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Decedent’s generation-skipping transfer exemption. |
| 200318062(PDF, 23K) |
5/2/2003 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending May 31 to a taxable year ending June 30, effective |
| 200318061(PDF, 29K) |
5/2/2003 |
| Requested ruling under § 301.9100-3(a) of the Procedure and Administration Regulations to file an election for Subsidiary to be treated as a disregarded entity for federal tax purposes. |
| 200318060(PDF, 56K) |
5/2/2003 |
| Requested rulings under § 29 of the Internal Revenue Code. |
| 200318059(PDF, 35K) |
5/2/2003 |
| Requested ruling under § 301.9100-3(a) of the Procedure and Administration Regulations that X be granted an extension of time to make an election under § 754 of the Internal Revenue Code for a transfer of a partnership interest occurring in the taxable year ending d1. |
| 200318058(PDF, 34K) |
5/2/2003 |
| Requested ruling that the income of Corporation is excludible from gross income under § 115 of the Internal Revenue Code and whether Corporation must file an annual federal income tax return. |
| 200318057(PDF, 38K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer exemption. |
| 200318056(PDF, 38K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make allocations of Generation-Skipping Transfer exemption. |
| 200318055(PDF, 30K) |
5/2/2003 |
| Requested ruling under § 877(c) of the Internal Revenue Code of 1986 that Taxpayer's loss of U.S. permanent resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200318054(PDF, 30K) |
5/2/2003 |
| Requested ruling under § 877(c) of the Internal Revenue Code of 1986 that Taxpayer's loss of U.S. permanent resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200318053(PDF, 29K) |
5/2/2003 |
| Requested extension of time under § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to make an alternate valuation election under § 2032 of the Internal Revenue Code. |
| 200318052(PDF, 26K) |
5/2/2003 |
| Requested ruling whether X should be treated as a S corporation. X was incorporated under the laws of State 1 on Date (1) The shareholders of X intended that X elect to be treated as a S corporation effective Date (1) However, the election to be treated as a S corporation was not timely filed. |
| 200318051(PDF, 33K) |
5/2/2003 |
| Request concerning the Federal income tax treatment under § 104 of the Internal Revenue Code of certain benefits paid under the Fund. |
| 200318050(PDF, 28K) |
5/2/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200318049(PDF, 29K) |
5/2/2003 |
| Requested ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200318048(PDF, 32K) |
5/2/2003 |
| Requested extension of time to make an election under § 1(h) of the Internal Revenue Code pursuant to § 311(e) of the Tax Reform Act of 1997, Pub. L. No. 105-34, for the Taxpayer’s taxable year ending January 31, 2001. The election is to recognize a deemed sale of certain assets held on January 1, 2001, and to commence a post-January 1, 2001, holding period for those assets. The Taxpayer filed the amended income tax return containing this election late because of conditions beyond its control. |
| 200318047(PDF, 48K) |
5/2/2003 |
| Requested rulings on certain federal income tax consequences of a proposed transaction. |
| 200318046(PDF, 67K) |
5/2/2003 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200318045(PDF, 32K) |
5/2/2003 |
| Requested extension of time under § 301.9100-1 of the Procedure and Administration Regulations to file a qualified physician’s certification with respect to the decedent’s incompetence as required by § 26.2601-1(b)(3) of the Generation-Skipping Transfer Tax Regulations. |
| 200318044(PDF, 36K) |
5/2/2003 |
| Requested extension of time under § 301.9100-1 of the Procedure and Administration Regulations to file a qualified physician’s certification with respect to the decedent’s incompetence as required by § 26.2601-1(b)(3) of the Generation-Skipping Transfer Tax Regulations. |
| 200318043(PDF, 32K) |
5/2/2003 |
| Requested extension of time under § 301.9100-1 of the Procedure and Administration Regulations to elect to treat Y as a qualified subchapter S subsidiary under § 1361(b)(3)(B) of the Internal Revenue Code. |
| 200318042(PDF, 32K) |
5/2/2003 |
| Requested extension of time under § 301.9100-1 of the Procedure and Administration Regulations to file a qualified physician’s certification with respect to the decedent’s incompetence as required by § 26.2601-1(b)(3) of the Generation-Skipping Transfer Tax Regulations. |
| 200318041(PDF, 29K) |
5/2/2003 |
| Requested ruling that A’s loss of lawful permanent resident status (expatriation) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200318040(PDF, 23K) |
5/2/2003 |
| Requested ruling under § 301.9100-3(a) of the Procedure and Administration Regulations that Partnership be granted an extension of time in which to make an election under § 754 of the Internal Revenue Code. |
| 200318039(PDF, 34K) |
5/2/2003 |
| Requested ruling regarding a qualified terminable interest property (QTIP) election made on Decedent’s federal estate tax return. |
| 200318038(PDF, 68K) |
5/2/2003 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200318037(PDF, 68K) |
5/2/2003 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200318036(PDF, 31K) |
5/2/2003 |
| Requested ruling that LLP be given an extension of time to elect under § 301.9100-3 of the Procedure and Administration Regulations to be classified as an association taxable as a corporation for federal tax purposes, and an extension of time to elect to be an S corporation under § 1362(b)(5) of the Internal Revenue Code. |
| 200318035(PDF, 32K) |
5/2/2003 |
| Requested ruling under 1362(f) of the Internal Revenue Code. |
| 200318034(PDF, 67K) |
5/2/2003 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200318033(PDF, 76K) |
5/2/2003 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200318032(PDF, 35K) |
5/2/2003 |
| Requested ruling under § 301.9100-3(a) of the Procedure and Administration Regulations for an extension of time to file an election to be treated as a qualified S corporation subsidiary and for late S election relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200318031(PDF, 67K) |
5/2/2003 |
| Requesting a schedule of ruling amounts relating to Plant's qualified nuclear decommissioning fund. |
| 200318030(PDF, 31K) |
5/2/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200318029(PDF, 29K) |
5/2/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200318028(PDF, 26K) |
5/2/2003 |
| Whether X will be recognized as an S corporation effective Date (1) X was incorporated under the laws of State 1 on Date (1) The election to be treated as a S corporation was not timely filed. |
| 200318027(PDF, 40K) |
5/2/2003 |
| Requested ruling on the application of the continuing employment exception to the hospital insurance portion (also known as Medicare tax) of the Federal Insurance Contributions Act (FICA) tax as set forth in Internal Revenue Code § 3121(u)(2)(C). |
| 200318026(PDF, 40K) |
5/2/2003 |
| Withdrawal of Request for a private letter ruling to make late elections of the appropriate percentage under § 42(b)(2)(A)(ii)(I) of the Internal Revenue Code pursuant to § 301.9100-3 of the Procedure and Administrative Regulations. |
| 200318025(PDF, 23K) |
5/2/2003 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending June 30, to a 52/53-week taxable year ending on the Saturday nearest January 31, effective February 2, 2002. |
| 200318024(PDF, 31K) |
5/2/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200318023(PDF, 28K) |
5/2/2003 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200318022(PDF, 26K) |
5/2/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200318021(PDF, 28K) |
5/2/2003 |
| Requesting inadvertent termination relief under § 1362(f) of the Internal Revenue Code. |
| 200318020(PDF, 36K) |
5/2/2003 |
| Requested ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200318019(PDF, 29K) |
5/2/2003 |
| Requested ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200318018(PDF, 31K) |
5/2/2003 |
| Requested ruling that X’s election to be treated as an S corporation was an inadvertent invalid election under § 1362(f) of the Internal Revenue Code. |
| 200318017(PDF, 32K) |
5/2/2003 |
| Requested ruling that egg donor fees and expenses related to obtaining a willing egg donor are allowable as medical care expenses under a flexible spending account. |
| 200318016(PDF, 26K) |
5/2/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200318015(PDF, 24K) |
5/2/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200318014(PDF, 42K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318013(PDF, 42K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318012(PDF, 42K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318011(PDF, 42K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318010(PDF, 47K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318009(PDF, 43K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318008(PDF, 43K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318007(PDF, 42K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318006(PDF, 43K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318005(PDF, 43K) |
5/2/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200318004(PDF, 31K) |
5/2/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200318003(PDF, 24K) |
5/2/2003 |
| Requested ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200318002(PDF, 32K) |
5/2/2003 |
| Issue: Whether the teachers and administrative staff of School are ministers of the gospel and therefore qualify for the parsonage allowance under Internal Revenue Code § 107. |
| 200318001(PDF, 38K) |
5/2/2003 |
| Requested ruling under § 301.9100-3(a) of the Procedure and Administration Regulations that X be granted an extension of time to make an election under § 1361(b)(3)(B) of the Internal Revenue Code for the taxable year beginning d2. |
| 200317054(PDF, 106K) |
1/31/2003 |
| Constitutes notice that with respect to the above-named defined benefit pension plan, the requested waiver for minimum funding standard for the plan year ended July 31, 2001, has been denied. Because the minimum funding standard for the plan year ended July 30, 2001, was not satisfied, the conditional waiver for the plan year ended July 30, 2000, previously granted by letter dated February 27, 2001, is now retroactively null and void. |
| 200317053(PDF, 106K) |
1/31/2003 |
| Constitutes notice that with respect to the above-named defined benefit pension plan, the requested waiver for minimum funding standard for the plan year ended July 31, 2001, has been denied. Because the minimum funding standard for the plan year ended July 30, 2001, was not satisfied, the conditional waiver for the plan year ended July 30, 2000, previously granted by letter dated February 27, 2001, is now retroactively null and void. |
| 200317052(PDF, 105K) |
1/31/2003 |
| Constitutes notice that with respect to the above-named defined benefit pension plan, the requested waiver for minimum funding standard for the plan year ended July 31, 2001, has been denied. Because the minimum funding standard for the plan year ended July 30, 2001, was not satisfied, the conditional waiver for the plan year ended July 30, 2000, previously granted by letter dated February 27, 2001, is now retroactively null and void. |
| 200317051(PDF, 248K) |
1/30/2003 |
| Requesting advance approval of grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200317050(PDF, 1.1M) |
1/30/2003 |
| Requested ruling concerning the characterization and tax consequences of certain proposed payments by Employer A to Plan X. |
| 200317049(PDF, 600K) |
1/30/2003 |
| Requested ruling regarding the treatment of stock received under a terminated pension plan as a result of the demutualization of Company B under § 4980 of the Internal Revenue Code. |
| 200317048(PDF, 337K) |
1/27/2003 |
| Requested ruling concerning a proposed restorative payment by Company A to Plan X. |
| 200317047(PDF, 715K) |
1/24/2003 |
| Requested ruling concerning the applicability of § 415(m) of the Internal Revenue Code to an excess plan and the tax consequences of certain related transactions. |
| 200317046(PDF, 342K) |
1/23/2003 |
| Requested ruling concerning the federal income tax treatment of certain contributions to Plan X under § 414(h)(2) of the Internal Revenue Code. |
| 200317045(PDF, 424K) |
1/3/2003 |
| Requesting five rulings on behalf of TRS. We have previously responded to requests one through four. We are now responding to request five. TRS is a defined benefit governmental plan covering teachers of the State. |
| 200317044(PDF, 722K) |
12/19/2002 |
| Requested ruling under § 401(a)(9) of the Internal Revenue Code. |
| 200317043(PDF, 719K) |
12/19/2002 |
| Requested ruling under § 401(a)(9) of the Internal Revenue Code. |
| 200317042(PDF, 522K) |
12/19/2002 |
| Requested ruling regarding certain tax consequences of a merger of the Domestic Plan into a Puerto Rican Plan and associated Trust to be established by a subsidiary of the entity that sponsors the Domestic Plan. |
| 200317041(PDF, 730K) |
12/19/2002 |
| Requested ruling under § 401(a)(9) of the Internal Revenue Code. |
| 200317040(PDF, 474K) |
12/18/2002 |
| Requested ruling under § 403(b)(8) of the Internal Revenue Code. |
| 200317039(PDF, 636K) |
12/12/2002 |
| Requested ruling concerning whether Plan X qualifies as a church plan under § 414(e) of the Internal Revenue Code. |
| 200317038(PDF, 746K) |
12/3/2002 |
| Requested ruling concerning whether Plan A and Plan B are church plans described in § 414(e) of the Internal Revenue Code and have continued to meet the requirements of § 414(e) since their inception. |
| 200317037(PDF, 490K) |
12/11/2002 |
| Requesting relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200317036(PDF, 701K) |
12/2/2002 |
| Issue: May an employer elect to aggregate two welfare benefit funds for purposes of computing unrelated business taxable income (UBTI) where one of the funds is exempt under § 501(c)(9) of the Internal Revenue Code and the other fund is not exempt? |
| 200317035(PDF, 475K) |
11/26/2002 |
| Requested ruling concerning whether Plan C is a church plan described in § 414(e) of the Internal Revenue Code and has continued to meet the requirements of § 414(e) since its inception. |
| 200317034(PDF, 601K) |
10/10/2002 |
| Requested ruling concerning the pick up of certain employee contributions to Plan X under § 414(h)2) of the Internal Revenue Code. |
| 200317033(PDF, 508K) |
11/26/2002 |
| Requested ruling concerning a proposed rollover of funds from one individual retirement account into another individual retirement account under § 408(d)(3) of the Internal Revenue Code. |
| 200317032(PDF, 468K) |
11/22/2002 |
| Requested ruling under § 408(d) of the Internal Revenue Code. |
| 200317031(PDF, 887K) |
11/4/2002 |
| Requested ruling concerning the above-named matched savings plan ("Plan X) under § 403(b) of the Internal Revenue Code. |
| 200317030(PDF, 508K) |
11/4/2002 |
| Requested ruling under § 414(e) of the Internal Revenue Code. |
| 200317029(PDF, 485K) |
10/15/2002 |
| Requested ruling that Plan X constitutes a church plan as described in Code § 414(e). |
| 200317028(PDF, 521K) |
10/7/2002 |
| Requesting relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200317027(PDF, 767K) |
10/3/2002 |
| Requested ruling concerning the amounts representing the 401(k) Transfers which are transferred by the 401(k) Plan on behalf of and at the direction of a Participant to the Plans in order to purchase service credit for the Member under the plans. |
| 200317026(PDF, 762K) |
10/3/2002 |
| Requested ruling concerning the applicability of § 415(m) of the Internal Revenue Code to an excess plan and the tax consequences of certain related transactions. |
| 200317025(PDF, 783K) |
10/2/2002 |
| Requested ruling concerning the applicability of § 415(m) of the Internal Revenue Code to an excess plan and the tax consequences of certain related transactions. |
| 200317024(PDF, 534K) |
9/30/2002 |
| Requested ruling concerning the pick up of certain employee contributions to Plan X under § 414(h)2) of the Internal Revenue Code. |
| 200317023(PDF, 674K) |
9/24/2002 |
| Requested ruling concerning the application of § 401(a)(28) of the Internal Revenue Code upon the spin-ff of an Employee Stock Ownership Plan (ESOP) from a profit sharing plan owning employer securities, and also concerning the allocation of shares of Company A's common stock upon the creation of ESOP. |
| 200317022(PDF, 745K) |
9/24/2002 |
| Requested ruling of the following: (1) Plan X, Y, and Z qualify as church plans within the meaning of § 414(e) of the Internal Revenue Code; (2) Plan X, Y and Z are exempt from the filing requirements of § 6058 of the Internal Revenue Code; (3) Employer M's transfer or rollover of all plan assets from Plan Y to Z will not cause participants' assets to be includible in income until the assets are distributed. |
| 200317021(PDF, 39K) |
4/25/2003 |
| Issues: (1) Whether a Form 1040, “U.S. Individual Income Tax Return,” shall be converted to a Form 1040NR, “U.S. Nonresident Alien Income Tax Return,” if the taxpayer fails to meet the green card or substantial presence test. (2) Whether the Internal Revenue Service may convert a Form 1040 to a Form 1040NR which would include the elimination of certain tax advantages; and, whether the filing of a Form 1040 return by a non-resident alien with an Individual Taxpayer Identification Number (ITIN) constitutes the filing of an income tax return and is considered a valid return. |
| 200317020(PDF, 84K) |
4/25/2003 |
| Requested rulings concerning the federal income tax consequences of a proposed transaction. |
| 200317019(PDF, 44K) |
4/25/2003 |
| Requested rulings on certain federal income tax consequences of a proposed transaction. The information submitted in this request and in subsequent correspondence is summarized below. The rulings in this letter are based on the facts and representations submitted under penalties of perjury in support of the request. Verification of that information may be required as part of the audit process. |
| 200317018(PDF, 31K) |
4/25/2003 |
| Requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat Sub as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200317017(PDF, 47K) |
4/25/2003 |
| Requested extension of time pursuant to § 2642(g) of the Internal Revenue Code and § 301.9100 of the Procedure and Administration Regulations, to make an allocation of Taxpayer’s generation-skipping transfer exemption. |
| 200317016(PDF, 149K) |
4/25/2003 |
| Issues: Under the facts described below, which party (Lessor or Lessee), should be subject to the § 274(n) deduction limitation relating to the reimbursement of meal and beverage expenses incurred by Workers while away from home in connection with the performance of their duties? |
| 200317015(PDF, 49K) |
4/25/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to sever a trust, to make a reverse qualified terminable interest property (QTIP) election, and to allocate Decedent’s Generation-Skipping Transfer tax exemption. |
| 200317014(PDF, 32K) |
4/25/2003 |
| Requesting on behalf of H and W for a private letter ruling granting permission to revoke an election out of the installment method pursuant to § 453(d) of the Internal Revenue Code. |
| 200317013(PDF, 44K) |
4/25/2003 |
| Requesting extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemption to transfers made to irrevocable trusts. |
| 200317012(PDF, 43K) |
4/25/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemptions to transfers made to irrevocable trusts. |
| 200317011(PDF, 40K) |
4/25/2003 |
| Proposed transaction regarding Husband’s Individually Owned Assets, Wife’s Individually Owned Assets, and the Jointly Owned Property (collectively, the “Assets): |
| 200317010(PDF, 29K) |
4/25/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200317009(PDF, 75K) |
4/25/2003 |
| Requesting a letter ruling concerning whether the transfer of an intertie from Generator to Taxpayer is a non-shareholder contribution to capital excludable from income under § 118(a) of the Internal Revenue Code. |
| 200317008(PDF, 37K) |
4/25/2003 |
| Requested extension of time under § 301.9100 of the Procedure and Administration Regulations to make a qualified family-owned business election under § 2057(b)(1)(B) of the Internal Revenue Code. |
| 200317007(PDF, 25K) |
4/25/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code regarding Company's late S corporation election. |
| 200317006(PDF, 31K) |
4/25/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200317005(PDF, 49K) |
4/25/2003 |
| Requesting a letter ruling concerning whether the transfer of certain bond proceeds and a parcel of land is a non-shareholder contribution to capital excludable from Taxpayer’s income under § 118(a) of the Internal Revenue Code. |
| 200317004(PDF, 37K) |
4/25/2003 |
| Requested ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200317003(PDF, 46K) |
4/25/2003 |
| Requested extension of time to make an election under § 311(e) of the Taxpayer Relief Act of 1997 (§ 311(e) election) for tax year 2001. |
| 200317002(PDF, 40K) |
4/25/2003 |
| Requested ruling that the rental income received by Company from the Properties will not be passive investment income under § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200317001(PDF, 24K) |
4/25/2003 |
| Requested rulings on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200316044(PDF, 669K) |
1/16/2003 |
| Requested rulings under § 414 (e) of the Internal Revenue Code. |
| 200316043(PDF, 288K) |
1/23/2003 |
| Request as to whether your involvement in V will affect your exempt status under § 501 (c)(3) of the Internal Revenue Code and foundation status under § 509 (a)(3) of the Internal Revenue Code. |
| 200316042(PDF, 123K) |
1/21/2003 |
| This letter is in response to the letter of your authorized representative dated December 19, 2002, and supplements the private letter ruling by our office dated December 2, 2002 (the "Ruling Letter). This notes amended parts of the Ruling Letter. |
| 200316041(PDF, 423K) |
1/21/2003 |
| Requested ruling submitted on the behalf by the authorized representative, concerning federal income tax treatment, under § 414(h)(2) of the Internal Revenue Code, of certain conditions to Plan X. |
| 200316040(PDF, 75K) |
4/18/2003 |
| Requested rulings: (1) Payments by the Trust of the following amounts from Fund A and Fund B to Class Members, are not subject to information reporting under § 6041 and withholding under § 1441; (2) Trust need not file duplicate payee statements to Class Members on whose behalf it makes payments for medical monitoring expenses directly to the medical service provider; and (3) Payments from Fund B of attorneys’ fees to class counsel and common benefit attorneys, and payment of amounts to fund medical research and education, are not made “on behalf of” any specific class member within the meaning of § 1.468B-2(1)(2)(ii), and therefore, the Trust need not send a duplicate payee statement to any class member with respect to such payments. |
| 200316039(PDF, 25K) |
4/18/2003 |
| Requested extension of time under Treasury Regulation § 301.9100-3 to file the agreements required by § 1.1503-2(g)(2)(i) with respect to the dual consolidated losses of Foreign Branch for the tax periods ended on Dates 1 and 2. |
| 200316038(PDF, 23K) |
4/18/2003 |
| Request that we supplement our letter ruling dated April 10, 2001 (PLR-130376-00) and our supplemental ruling dated May 20, 2002 (PLR-126187-02). The original letter ruling and the supplemental ruling are together referred to as the “Prior Letter Ruling.” Capitalized terms not defined in this ruling have the meanings originally assigned to them in the Prior Letter Ruling. |
| 200316037(PDF, 31K) |
4/18/2003 |
| Requested ruling under § 877(c) of the Internal Revenue Code of 1986 that A’s loss of U.S. citizenship did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Internal Revenue Code. |
| 200316036(PDF, 47K) |
4/18/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer exemption. |
| 200316035(PDF, 47K) |
4/18/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer exemption. |
| 200316034(PDF, 56K) |
4/18/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer Tax exemption. |
| 200316033(PDF, 57K) |
4/18/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of Generation-Skipping Transfer Tax exemption. |
| 200316032(PDF, 28K) |
4/18/2003 |
| Requesting that the Service grant X an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat Sub as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200316031(PDF, 49K) |
4/18/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of the generation-skipping transfer tax exemption. |
| 200316030(PDF, 36K) |
4/18/2003 |
| Requested ruling under § 1362(f) of the Internal Revenue Code. |
| 200316029(PDF, 27K) |
4/18/2003 |
| Requested ruling that it be granted an extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations in which to elect to be treated as a disregarded entity for federal tax purposes under § 301.7701-3(c). |
| 200316028(PDF, 24K) |
4/18/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200316027(PDF, 35K) |
4/18/2003 |
| Requested extension of time under § 301.9100-1 of the Procedure and Administration Regulations to make an election under § 856(l) of the Internal Revenue Code to treat Company B as a taxable REIT subsidiary of Company A. |
| 200316026(PDF, 27K) |
4/18/2003 |
| Requested extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat Sub as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code. |
| 200316025(PDF, 29K) |
4/18/2003 |
| Requested ruling that X be given an extension of time to elect under § 301.9100-3 of the Procedure and Administration Regulations to be classified as an association taxable as a corporation for federal tax purposes and relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200316024(PDF, 27K) |
4/18/2003 |
| Submitted on behalf of X, Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations for X to elect to be classified as an association taxable as a corporation for federal tax purposes. |
| 200316023(PDF, 37K) |
4/18/2003 |
| Requested ruling regarding the generation-skipping transfer tax consequences of the proposed modification to Trust. |
| 200316022(PDF, 50K) |
4/18/2003 |
| Requested rulings under § 29 of the Internal Revenue Code. |
| 200316021(PDF, 29K) |
4/18/2003 |
| Requested extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election under § 754 of the Internal Revenue Code. |
| 200316020(PDF, 35K) |
4/18/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code and § 301.9100-3 of the Procedure and Administration Regulations. |
| 200316019(PDF, 73K) |
4/18/2003 |
| Requesting a letter ruling concerning whether the transfer of an intertie from Generator to Taxpayer is a non-shareholder contribution to capital excludable from income under § 118(a) of the Internal Revenue Code. |
| 200316018(PDF, 27K) |
4/18/2003 |
| Requested extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat a subsidiary as a qualified subchapter S subsidiary under § 1361(b)(3)(B) of the Internal Revenue Code. |
| 200316017(PDF, 27K) |
4/18/2003 |
| Requested extension of time pursuant to § 301.9100-3 of the Procedure and Administration Regulations to elect to treat a subsidiary as a qualified subchapter S subsidiary under § 1361(b)(3)(B) of the Internal Revenue Code. |
| 200316016(PDF, 22K) |
4/18/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200316015(PDF, 31K) |
4/18/2003 |
| Requested ruling that the rental income received by X in the course of its operations from commercial properties is not passive investment income within the meaning of § 1362(d)(3) of the Internal Revenue Code. |
| 200316014(PDF, 34K) |
4/18/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent is Requested extension to file a “§ 338 election” under § 338(g) with respect to Parent’s acquisition of the stock of Target on Date B. |
| 200316013(PDF, 34K) |
4/18/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent is Requested extension to file a “§ 338 election” under § 338(g) with respect to Parent’s acquisition of the stock of Target on Date B. |
| 200316012(PDF, 27K) |
4/18/2003 |
| Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200316011(PDF, 61K) |
4/18/2003 |
| Issue: Whether the Internal Revenue Service may publicize information, such as criminal tax prosecutions, injunctions and convictions of promoters and/or participants of abusive tax schemes, in the Tenth Internal Revenue Code. |
| 200316010(PDF, 25K) |
4/18/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200316009(PDF, 25K) |
4/18/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200316008(PDF, 49K) |
4/18/2003 |
| Requested rulings under § 691(c) of the Internal Revenue Code, submitted on behalf of Executor by Executor’s authorized representative. |
| 200316007(PDF, 27K) |
4/18/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200316006(PDF, 29K) |
4/18/2003 |
| Requesting that Partnership be granted an extension of time under § 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to make an election under § 754 of the Internal Revenue Code. |
| 200316005(PDF, 30K) |
4/18/2003 |
| Requesting that the Service grant X an extension of time pursuant to § 301.9100 of the Procedure and Administration Regulations to elect to treat S as a qualified subchapter S subsidiary under § 1361(b)(3) of the Internal Revenue Code effective D1. |
| 200316004(PDF, 43K) |
4/18/2003 |
| Requesting inadvertent invalid election relief under § 1362(f) of the Internal Revenue Code. |
| 200316003(PDF, 98K) |
4/18/2003 |
| Requested rulings under § 29 and § 702 of the Internal Revenue Code. |
| 200316002(PDF, 24K) |
4/18/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200316001(PDF, 18K) |
4/18/2003 |
| Requested assistance in the above case. In accordance with § 6110(k)(3) of the Internal Revenue Code, this memorandum should not be cited as precedent. |
| 200315041(PDF, 981K) |
1/17/2003 |
| Requested rulings concerning Issues: arising under § 402 of the Internal Revenue Code. |
| 200315040(PDF, 660K) |
1/16/2003 |
| Requested ruling dated June 24, 2002 concerning the federal Income and private foundation tax consequences of a judicially authorized amendment of the Trust that would eliminate all non charitable interests in the Trust. |
| 200315039(PDF, 282K) |
1/15/2003 |
| Requested ruling on the proper treatment of vesting service credit under Plan A upon its merger with Plan B under § 401(a)(7) and 411 of the Internal Revenue Code. |
| 200315038(PDF, 423K) |
1/15/2003 |
| Requested ruling that the establishment of a § 401(h) account within the Plan and the transfer of excess pension assets to such account in accordance with § 420 of the Internal Revenue Code will not cause the Plan to fail to be qualified plan under § 401(a) of the Internal Revenue Code. |
| 200315037(PDF, 122K) |
1/15/2003 |
| Notice that with respect to the above-named defined benefit pension plan we have granted a waiver of the minimum funding standard for the plan year ending December 31, 2001. |
| 200315036(PDF, 123K) |
1/15/2003 |
| Notice that with respect to the above-named defined benefit pension plan we have granted a waiver of the minimum funding standard for the plan year ending December 31, 2001. |
| 200315035(PDF, 674K) |
1/14/2003 |
| Requested ruling involving under § 512 and 4941 of the Internal Revenue Code. Specifically, we are responding to the ruling requests concerning unrelated business taxable income as well as self-dealing. |
| 200315034(PDF, 677K) |
1/14/2003 |
| Requested ruling involving under § 512 and 4941 of the Internal Revenue Code. Specifically, we are responding to the ruling requests concerning unrelated business taxable income as well as self-dealing. |
| 200315033(PDF, 238K) |
1/14/2003 |
| Requested advance approval of the grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200315032(PDF, 676K) |
1/14/2003 |
| Requested ruling involving under § 512 and 4941 of the Internal Revenue Code. Specifically, we are responding to the ruling requests concerning unrelated business taxable income as well as self-dealing. |
| 200315031(PDF, 747K) |
1/14/2003 |
| Requested ruling under § 4941 of the Internal Revenue Code submitted on M's behalf by M's authorized representative as modified. M has requested a ruling involving O's services to partnership N. |
| 200315030(PDF, 171K) |
1/14/2003 |
| Conditional waiver of the minimum funding standard which has been granted for the above-named pension plan for the plan year ending March 31, 2002. |
| 200315029(PDF, 240K) |
1/14/2003 |
| Requested advance approval of the grant procedures under § 4945(g) of the Internal Revenue Code. |
| 200315028(PDF, 684K) |
1/13/2003 |
| Requested ruling concerning unrelated business taxable income as well as self-dealing. |
| 200315027(PDF, 599K) |
1/9/2003 |
| Requesting relief under § 301.9100-3 of the Procedure and Administration Regulations. |
| 200315026(PDF, 27K) |
4/11/2003 |
| Requested ruling on the proper Federal income tax treatment under § 104 of the Internal Revenue Code (the Internal Revenue Code) of certain disability benefits you receive. |
| 200315025(PDF, 32K) |
4/11/2003 |
| This letter is in reply to your letter dated November 15, 2002, requesting supplemental rulings regarding the distribution by Distributing to its shareholders of the stock of Controlled, formerly a directly wholly owned subsidiary of Distributing (the “Distribution). |
| 200315024(PDF, 30K) |
4/11/2003 |
| Requested extension of time under § 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file an election under § 168(h)(6)(F)(ii) of the Internal Revenue Code (the "Election). |
| 200315023(PDF, 51K) |
4/11/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations and § 2642(g) of the Internal Revenue Code to make allocations of Trustor’s generation-skipping transfer tax exemptions to certain transfers to an irrevocable trust. |
| 200315022(PDF, 45K) |
4/11/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make a reverse qualified terminable interest property (QTIP) election under § 2652 of the Internal Revenue Code. |
| 200315021(PDF, 104K) |
4/11/2003 |
| Issues: (1) When does the period of limitations for assessment of a deficiency attributable to Partnership’s gain on an involuntary conversion expire? (2) Does the special limitations period of § 1033(a)(2)(C) extend the period of limitations for assessment of a deficiency against Pcorp, the common parent of Sub 1, attributable to Partnership’s gain on the involuntary conversion? |
| 200315020(PDF, 36K) |
4/11/2003 |
| Submitted on behalf of X, Requesting relief under § 1362(f) of the Internal Revenue Code. |
| 200315019(PDF, 34K) |
4/11/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent is Requested extension to file a “§ 338 election” under § 338(g) with respect to Parent’s acquisition of the stock of Target on Date B. |
| 200315018(PDF, 34K) |
4/11/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent is Requested extension to file a “§ 338 election” under § 338(g) with respect to Parent’s acquisition of the stock of Target on Date B. |
| 200315017(PDF, 27K) |
4/11/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200315016(PDF, 66K) |
4/11/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to sever a trust into an exempt and nonexempt trust for purposes of Generation-Skipping Transfer tax and to make a “reverse” qualified terminable interest property (QTIP) election under § 2652(a)(3) of the Internal Revenue Code with respect to the exempt trust. |
| 200315015(PDF, 79K) |
4/11/2003 |
| Requested rulings regarding the effect of the proposed settlement agreement for federal gift, income and generation-skipping transfer tax purposes. |
| 200315014(PDF, 23K) |
4/11/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200315013(PDF, 42K) |
4/11/2003 |
| Requested rulings regarding the generation-skipping transfer tax consequences of the proposed division of and modifications to Trust. |
| 200315012(PDF, 31K) |
4/11/2003 |
| Requested ruling that a portion of a pooled bond Issue, the proceeds of which are reasonably expected to be lent to one or more local government borrowers to refinance prior debt of that local government borrower(s) more than 90 days after the Issue: date of the pooled bond Issue, can be treated as a separate Issue: for § 149(d)(3)(A)(i), (ii) and (iii) of the Internal Revenue Code. |
| 200315011(PDF, 25K) |
4/11/2003 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. |
| 200315010(PDF, 25K) |
4/11/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200315009(PDF, 26K) |
4/11/2003 |
| Requested confirmation of X’s tax classification for federal tax purposes. |
| 200315008(PDF, 39K) |
4/11/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer tax exemption. |
| 200315007(PDF, 26K) |
4/11/2003 |
| Requested ruling under § 1362(b)(5) of the Internal Revenue Code. |
| 200315006(PDF, 40K) |
4/11/2003 |
| Requested extension of time under § 301.9100-3 of the Procedure and Administration Regulations to make an allocation of generation-skipping transfer tax exemption. This letter responds to your request. |
| 200315005(PDF, 54K) |
4/11/2003 |
| Issues: (1) Under the facts set forth below, what transportation and delivery charges are excludable by Taxpayer in determining its taxable sale price of a truck semi trailer subject to the excise tax imposed by § 4051(a)(1) of the Internal Revenue Code? (2) For purposes of the tax imposed by § 4051(a)(1), may Taxpayer exclude from its taxable sale price of a semi trailer charges for lights and dock bumpers installed on the vehicle by the manufacturer? |
| 200315004(PDF, 54K) |
4/11/2003 |
| Whether the portion of the interest payments on mortgage loans (financed with the proceeds of mortgage revenue bonds under § 143 of the Internal Revenue Code of 1986 (the 1986 Code)) used to pay the Government National Mortgage Association (GNMA) to guarantee the payment on the mortgage loans must be taken into account in determining the effective rate of interest on the mortgage loans for purposes of § 143(g). |
| 200315003(PDF, 70K) |
4/11/2003 |
| Request for a ruling that the costs of goods and services made available by Y without charge to its customers and involving the use of facilities operated by third parties on Y’s premises (hereinafter “comps), are deductible without regard to limitations in § 274 of the Internal Revenue Code. |
| 200315002(PDF, 39K) |
4/11/2003 |
| Requested a ruling concerning the generation-skipping transfer tax consequences of the proposed judicial construction of a trust agreement that is exempt from the application of GST tax imposed under § 2601 of the Internal Revenue Code. |
| 200315001(PDF, 39K) |
4/11/2003 |
| Requested rulings that a corporate restructuring of the taxpayer’s business will not result in a deemed exchange of debt pursuant to § 1001 of the Internal Revenue Code. |
